Corporate Taxes United Kingdom

News & Analysis as of

UK Tax: When Partnership Is Not Partnership

The recent decision of the First Tier Tribunal (FTT) in the unusual case of R. Ashton v HMRC [2016] UKFTT 727 serves as a useful reminder to taxpayers of two issues: (1) the potential for confusion when distinguishing between...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

UK tax deductibility of corporate interest expense

The 2016 Budget announced, and the UK government is currently consulting on, the biggest change in UK tax this century. Up until 1st April 2017, a tax deduction for interest costs of up to 100% of UK profits is (very broadly)...more

Tax break for infrastructure projects

To implement the G20/OECD base erosion and profit shifting project, the 2016 Budget announced measures limiting tax deductions that companies can claim from their interest expenses (read DLA Piper's earlier client alert on...more

Country by Country: United Kingdom

Introduction - The UK CbC reporting regulations ("The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016") were made on 26 February 2016....more

Focus on Tax Strategies & Developments - December 2016

Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more

UK: when the Diverted Profits Tax and the expanded royalty withholding tax rules interact

Two ways in which the UK government has recently sought to increase the amount of tax payable in the UK by non-resident companies have been to impose a new Diverted Profits Tax (DPT) and to amend its existing 20 percent...more

U.K. Autumn Statement 2016: Key Implications for Investment Funds

On Wednesday 23 November 2016, Philip Hammond delivered the U.K. Autumn Statement, which included a number of announcements of relevance to the financial services industry. While relatively few new tax measures were...more

UK Autumn Statement 2016: corporate

The Government has recommitted to the following reforms previously trailed in the March 2016 Budget: The Government also announced the following new initiatives...more

UK Autumn Statement 2016: finance

In the 2016 Autumn Statement, the UK government confirmed, as previously announced, that from April 2017, it is to cap the amount of tax deductions for interest to the higher of 30% of taxable earnings in the UK or the net...more

UK Autumn Statement 2016: real estate

Interest relief restrictions - The adoption of the interest deductibility restrictions from April 2017 onwards will continue. The basic elements of the rules will remain as previously announced - a cap on deductions at...more

"Double Trouble": The Kenyan Constitution and DTAs

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

UK Autumn Statement 2016: IPT

No major changes were announced (subject to legislation to be published on 5 December), but we set out below a brief summary of the announcements which are relevant to corporates in the IPT sector....more

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

The Chancellor’s Autumn Statement

It’s that time of the quarter again and Chancellor Philip Hammond’s first (and last) Autumn Statement. It’s also the first Statement ‘post-Brexit’. The focus of the Statement has, as predicted, been on austerity versus...more

Globally Taxing Issues for Private Equity

Tax has, in recent months, become a frontpage issue with reaction to businesses not “paying their fair share” sitting alongside pressure on government finances and an uncertain political environment. In our view, the...more

Using corporate structures to own UK residential property – a dead end?

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

Brexit: An Opportunity to Readjust UK Tax Policy?

The U.K. government mantra has for a number of years been: "Britain is open for business." This has been reflected in a number of areas relevant to U.K. domestic and foreign tax policy, including in a gradual reduction of the...more

Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

Implications of the UK’s Brexit Referendum

As autumn approaches and preparation for the next round of Brexit discussions begins, this note summarises the current position and analysis following the UK’s vote to leave the EU on the 23rd June (the “Referendum”). Whilst...more

UK Government Confirms Introduction of New Cap on Interest Deductibility

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

What Does Brexit Mean for UK Tax?

Once the formal procedure under Article 50 of the Lisbon Treaty is initiated by the United Kingdom, the government will negotiate the terms of its exit from the European Union. Whilst we must accept that this is a period of...more

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Five Ways that Brexit Will Complicate Cross-Border M&A

This week's referendum in the UK and the decision for Great Britain to exit the European Union (EU) has caused turmoil in financial markets. For M&A practitioners, however, the impact is only just beginning. Below are five...more

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